Commonwealth Fisheries Association - additional

19 July 2011

Manager, Fisheries Policy and Environment
Department of Agriculture Fisheries and Forestry
GPO Box 858
Canberra ACT 2601

Supplementary Submission – Australia’s 2011 National Plan of Action for the Conservation and Management of Sharks – Shark-plan 2

In addition to our letter dated 18 July, the CFA would like to add the following few comments on the draft Shark Plan 2 for your consideration. In general, as per our earlier note, we consider that the plan is a good one. Notwithstanding, we consider the plan leaves a number of areas unresolved, or unclear, from an industry perspective. In that regard, I would appreciate if you could also consider the following as comments from CFA:

1. In table 2 for issue 1 - CFA suggests the actions include reference to not only reviewing and monitoring identification guides but also the practices for ensuring the guides are adopted by those whose activities interact with sharks
2. CFA notes that SIRC will be responsible for shark plan 2 implantation, monitoring and evaluation as we understand it. CFA suggests that the composition of this committee be expanded to include broader stakeholder representation, including fishing industry, NGO, scientific.
3. CFA suggests that SIRC would benefit from increased transparency and communication of their activities including how their performance is measured against objectives. For example, does/will SIRC coordinate the many research and management programs existing around Australia for sharks, and avoiding duplication? CFA notes the recent FRDC project on shark bycatch mitigation strategies which they thought was a deliverable of Shark Plan 1. It would be useful if SIRC could confirm if the outcomes of that study will be included in our international response, and that activities such as this will not be inadvertently replicated under Shark Plan 2.
4. CFA considers the plan does not give enough attention to the impact of recreational fisheries on sharks and therefore greater emphasis should be on understanding those impacts and managing them. In addition, we believe the focus should be at a fisher level for implementing conservation outcomes around handling and release of sharks and so on. To this end the priority should shift from medium to high for the actions against issue 8, 10 and 14.
5. CFA recommends that the plan could be greatly improved if accompanied by an implementation plan and budget.

Thank you for the opportunity to provide input. Please contact me if you have any queries on the matters raised above.

Yours sincerely

[signed]

Trixi Madon
CEO